Westminster child abuse inquiry to hear Margaret Thatcher was presented ‘allegations of unnatural sexual proclivities’, Prince Andrew denies sex abuse claims, NSW may extend time limit on child sex abuse claims

January 23, 2015 Comments Off on Westminster child abuse inquiry to hear Margaret Thatcher was presented ‘allegations of unnatural sexual proclivities’, Prince Andrew denies sex abuse claims, NSW may extend time limit on child sex abuse claims

Westminster child abuse inquiry to hear Margaret Thatcher was presented ‘allegations of unnatural sexual proclivities’
Secret document suggests claims against ‘public figures’ were taken to the PM at height of alleged paedophile scandal  Adam Withnal Wednesday 21 January 2015

A UK academic has uncovered a file which he claims could contain allegations of “unnatural” sexual activities against public figures at the height of the Westminster child abuse scandal.

Dr Chris Murphy, a security and intelligence lecturer at the University of Salford, found the classified document while searching the National Archives in Kew.

While its contents have not been made public, Dr Murphy said he was immediately alerted by the title showing it had been taken to the then-Prime Minister, Margaret Thatcher.

The title read: “PREM19/588 – SECURITY. Allegations against former public [word missing] of unnatural sexual proclivities; security aspects 1980 Oct 27 – 1981 Mar 20.”

According to Sky News, the Cabinet Office has been made aware of the file and it will be made available to the ongoing panel inquiry into the alleged existence of a paedophile ring involving senior Westminster figures….
http://www.independent.co.uk/news/uk/crime/westminster-child-abuse-inquiry-to-receive-evidence-of-unnatural-sexual-proclivities-9991716.html

‘Unnatural Sex’ File Given To Abuse Inquiry 
  The secret document was not handed over to a review into child abuse, the chief executive of the NSPCC tells Sky News.  UK, Wednesday 21 January 2015
By Tom Parmenter, Sky News Correspondent

A secret file on “unnatural” sexual behaviour was not handed over to a Government backed review that looked for official documents linked to child abuse.

The file prepared for then Prime Minister Margaret Thatcher in the 1980s was found recently at the National Archives in Kew and is entitled:  “PREM19/588 – SECURITY. Allegations against former public [word missing] of unnatural sexual proclivities; security aspects 1980 Oct 27 – 1981 Mar 20”.

The Cabinet Office still holds the file. Thirty-five years after it was prepared it remains closed on grounds of national security….

It is highly likely Margaret Thatcher saw the documents, and was briefed on the security implications, but the identities of those within them remain secret.

Dr Murphy added: “The fact that this file is concerning the Prime Minister and these allegations are being taken to the Prime Minister I think would strike anybody of being potentially of some interest.”….

Mrs Thatcher’s former press secretary, Sir Bernard Ingham, told Sky News he could not recall the file.

He did, though, confirm that both he and Mrs Thatcher were aware of allegations against a Government minister in the early 1980s.

Sir Bernard would not name the individual, but said: “I asked him about it and he denied it, so no, I didn’t do anything else. What was the alternative?”….

Officials at the Cabinet Office have previously attempted to block requests for information relating to Cyril Smith, the late Liberal politician who is now known to have abused youngsters….
http://news.sky.com/story/1411734/unnatural-sex-file-given-to-abuse-inquiry

NSW may extend time limit on child sex abuse claims
Royal commission into institutional responses to child sexual abuse has shown survivors do not disclose or act on their experience until decades after abuse
Brad Hazzard
Attorney general Brad Hazzard: under the NSW Statute of Limitations people abused as children generally have three to 12 years from the time of the offence to launch a civil claim.
Australian Associated Press  Thursday 22 January 2015

The NSW government is considering lifting the time limit in which survivors of child sexual abuse can sue for damages.

The NSW attorney general Brad Hazzard said the royal commission into institutional responses to child sexual abuse had uncovered widespread claims about abuse and the legal barriers survivors face in pursuing justice many years after the crime.

“It is well documented that many survivors of child sexual abuse do not disclose their experiences or act on them until decades after the abuse, well after the time period has ended,” Hazzard said on Friday.

The government has released a discussion paper on whether to amend the Limitation Act 1969 and wants to hear from the public.

Under the NSW Statute of Limitations people abused as children generally have between three and 12 years from the time of the offence to launch a civil claim.

“People who have suffered at the hands of others sometimes take 20, 30 years just to build up the courage to be able to say anything … it’s a bit strange that there’s a limitation in the law that says you can’t bring proceedings,” Hazzard told ABC radio on Friday….
http://www.theguardian.com/australia-news/2015/jan/23/nsw-may-extend-time-limit-on-child-sex-abuse-claims

Prince Andrew denies sex abuse claims
By Laura Smith-Spark and Lindsay Isaac, CNN  January 22, 2015
(CNN)In his first public remarks since being accused of having sex with an underage American woman, Britain Prince Andrews briefly addressed the allegation before a crowd in Davos, Switzerland.

“Firstly, I think I must, want, for the record to refer to the events that have taken place in the last three weeks. And I just wish to reiterate and to reaffirm the statements which have already been made on my behalf by Buckingham Palace,” he said Thursday at the World Economic Forum.

Earlier this month, Buckingham Palace issued a statement which said, “It is emphatically denied that the Duke of York [Andrew] had any form of sexual contact or relationship” with the woman. “Any claim to the contrary is false and without foundation.”

Andrew is a son of Queen Elizabeth II and a brother of Prince Charles, the next in line for the British throne….

The woman, identified by Buckingham Palace as Virginia Roberts, first named the prince in a civil motion filed December 30 in the U.S. District Court in southern Florida in which she claims she was forced to have sex with several men. She is referred to as Jane Doe No. 3 in the legal filings.

In the letter the woman’s lawyers sent to Buckingham Palace, attorneys Paul Cassell and Bradley Edwards asked to interview Prince Andrew “under oath regarding interactions that you had with Jane Doe No. 3 beginning in approximately early 2001. Jane Doe No. 3 was then 17 years old.”

The letter includes a picture of the woman and Andrew which was taken around that time, they say. The lawyers also want to discuss subsequent interactions with their client in New York City later that year, the letter says….
http://www.cnn.com/2015/01/22/europe/prince-andrew-sex-abuse-allegations/

 

New Child Sex Abuse Claims Filed Against Michael Jackson, Wyoming couple accused of keeping child in a cage

August 8, 2014 Comments Off on New Child Sex Abuse Claims Filed Against Michael Jackson, Wyoming couple accused of keeping child in a cage

New Child Sex Abuse Claims Filed Against Michael Jackson
By Melody Chiu 8/07/2014

Five years after his sudden passing, Michael Jackson is being accused of sexual abuse by a man who claims he was molested as a child by the superstar.

In court papers filed Monday, James Safechuck, 36, alleges he was abused by the singer when he was 10 years old after appearing in a Pepsi commercial with him.

After multiple visits to Jackson’s home (some of which were chaperoned by his parents) and several all-expense-paid cross-country trips, Safechuck joined the pop star on his “Bad” tour, which is when he alleges the first incident of sexual abuse occurred….

The papers allege Jackson gave Safechuck jewelry as a “reward” for sexual favors and taught him code words so others wouldn’t learn about their sexual activities.

The Jackson estate slammed the allegations Wednesday in a statement to E! News….

Claiming he was the first to stay at Jackson’s famed Neverland Ranch after it was built, Safechuck states in the papers that the pop star “installed chimes in the hallway to his bedroom” so he could be warned of people approaching and had a “secret closet” in his bedroom where he engaged in sexual activities with Safechuck.

During the four years that Safechuck claims the abuse took place, Jackson engaged in sexual acts with him “hundreds of times – on tour, at Plaintiff’s home, at DECEDENT’s apartment/condominium … at DECEDENT’s … Condominium … and at Neverland,” the papers say.

When Safechuck hit puberty at 12 years old, Jackson began “grooming him for separation [that] spanned several months” and focusing his attention on a younger boy named Brett, Safechuck claims….
http://www.people.com/article/new-sexual-abuse-claims-against-michael-jackson

Wyoming couple accused of keeping child in a cage
Robert Garrison, KUSA  August 5, 2014
An affidavit reveals the family had at least eight previous contacts with authorities but the child remained at the home.

LARAMIE, Wyo. – Authorities in Wyoming are pressing felony charges against a man and a woman alleging they kept a 7-year-old child in an outdoor cage.

The child’s mother, Jena Harman, and her boyfriend, Alexander Smith, face one count each of child abuse and three counts each of felonious restraint.

The pair were arrested July 24 after Albany County Sheriff’s deputies responded to a tip that the child was caged outside a home on Fox Creek Road.

The July 24 visit was not the only time the sheriff’s office was called to check on the child. Deputies went to the pair’s property on multiple occasions starting in February of this year.

Deputies said the child reported living in the 6-by-6-foot cage on and off for three weeks, taking meals there and sleeping there overnight, even during rainstorms….

The child’s school had complained to the sheriff’s office several times – saying the child had come to school with bruises and a limp. But each time, the sheriff’s office said the reports were unfounded. At one point, deputies witnessed the kid pulling food out of a garbage can and eating it in front of them.

Neighbors told 9NEWS they saw the abuse firsthand but didn’t report it, because they were scared of retribution from the mother’s boyfriend….
http://www.9news.com/story/news/crime/2014/08/05/caged-child/13634807/

Paedo MP cover-up claim: Top cop removed from sex abuse probe after naming politicians as suspects, Anger rises in Gabon after rash of ritual killings, Ritual Abuse Crimes, Ritual Abuse Legal Codes

March 27, 2013 Comments Off on Paedo MP cover-up claim: Top cop removed from sex abuse probe after naming politicians as suspects, Anger rises in Gabon after rash of ritual killings, Ritual Abuse Crimes, Ritual Abuse Legal Codes

Paedo MP cover-up claim: Top cop removed from sex abuse probe after naming politicians as suspects
By Tom Pettifor 26 Mar 2013

The officer suddenly found himself booted off the case and put on a disciplinary after revealing ­politicians were among the suspects

Tasked with flushing out ­paedophiles preying on vulnerable youngsters at children’s homes, Detective Chief Inspector Clive Driscoll relished the challenge.

But the officer suddenly found himself booted off the case and put on a ­disciplinary after revealing ­politicians were named among the suspects. At least one of the figures is understood to have been an MP.

And former Labour councillor Anna Tapsell claims she was visited by a police chief to “warn her off” after she raised concerns that detectives would not ­properly investigate allegations of ­paedophile activity in care homes.

Mr Driscoll launched his probe into child sex abuse claims in the South London borough of Lambeth in 1998. But he claims Scotland Yard began meddling as soon as the politicians were named….

The Met set up a five year investigation into sexual abuse linked to Lambeth social care called Operation Middleton. It was a joint probe with the council and was based in the town hall, leading to criticism that the Met were working too closely with the organisation that had employed abusers.

Officers traced 200 victims between 1998 to 2003 and the probe secured three convictions. A total of 19 suspects were never identified, fuelling fears a ­paedophile ring had operated involving men from outside the care system.

Michael John Carroll, the former boss of the Angell Road home, was arrested in 1998 by Merseyside police for abuse spanning decades. By that time Ms Tapsell had spent more than 10 years highlighting his case after she discovered Lambeth bosses let him run children’s homes until 1991 despite ­executives learning in 1986 he was a convicted ­paedophile.

In 1994, she wrote to Elizabeth Appleby QC, who had been ­commissioned to head a probe into sex abuse and misconduct in the borough. Ms Tapsell told the judge that Carroll, who had not at that point been arrested, was “protected” by Lambeth social ­services bosses along with paedophile Les Paul who worked in South Vale.

Paul was jailed for two and a half years in 1994 for abusing three boys including one from the children’s home. Ms Tapsell wrote: “Les Paul took little boys home and on holiday, just as Carroll did with the full knowledge of area staff. The examples are numerous.

“Almost all the internal abuse issues have involved collusion across divisions.
“I have no doubt Angell Road may have been used for organised child abuse which involved adults other than staff. “This view is reinforced by the strong investment that officers and politicians have in blocking any effective investigation.”….
http://www.mirror.co.uk/news/uk-news/paedophile-mp-cover-up-claim-detective-1785273

Anger rises in Gabon after rash of ritual killings
By Jean Rovys Dabany Reuters 3/26/13

LIBREVILLE (Reuters) – A rising number of mutilated bodies washing up on Gabon’s beaches this year has sown fear in the normally sleepy capital Libreville of a resurgence in ritual killings.

The body parts of humans and animals are prized by some in central Africa for their supposed supernatural powers, including among some politicians bent on gaining influence.

“We have seen 20 killings since the start of the year,” said Jean-Elvis Ebang Ondo, the president of Gabon’s Association for the Prevention of Ritual Crimes, in Libreville….

“The phenomenon of ritual crimes is real. But no one here is willing to turn anyone else in for fear they too will be in danger,” said a member of parliament, who asked that his name not be used for fear of reprisals.

In the most high-profile ritual murder court case in Gabon to date, a convicted killer accused a Gabonese senator of ordering the 2009 murder of a 12-year-old girl for her organs.

The senator’s immunity was lifted after the accusation was made late last year, but he has not been indicted. The senator has denied any involvement….
http://news.yahoo.com/anger-rises-gabon-rash-ritual-killings-161117150.html

Criminal sentence – Colin David Batley – court  Swansea Crown Court
Colin David Batley….
Total Sentence : 11 Years…

Distinguishing Features/Facts : He was the leader of a cult which operated as a paedophile ring sexually abusing children, both male and female, as young as 10-years-old over a period of at least 10-years. Children were told if they behaved and did what they were told that they would be rewarded in the afterlife by going to ‘The Palace’ where they would be looked after by the gods, otherwise they would fall into the abyss. They were also threatened with assassination by the cult. Two female victims became pregnant as a result of the rapes and were told children conceived within the cult belonged to the cult. One of the victims went to the police fearing her child would also become a victim of the cult.

He faced 36 charges and was sentenced on 35 offences. He was found not guilty of one count of rape which he faced with a co-defendant and he pleaded guilty to an indecent assault….
http://www.thelawpages.com/court-cases/Colin-David-Batley-6480-1.law

Blood-drinking devil worshippers face life for ritual Satanic killing
Murder trial reveals sinister link to British vampire groups     John Hooper in Berlin
The Guardian, Thursday 31 January 2002

A young married couple who admitted to a ritual Satanic killing were yesterday told they could spend the rest of their lives in a secure psychiatric unit after a trial which has raised the spectre of bizarre underground occult groups in Britain.

Manuela Ruda, aged 23, who told a German court she had become a vampire in London, and her husband, Daniel, aged 26, were given prison sentences of 13 and 15 years respectively after admitting to the hacking to death of a friend in their flat in Witten, in the Ruhr valley.
….The couple stabbed Hackert 66 times, carving an occult pentagram on his chest and collecting his blood in a bowl and then drinking it. When police broke into the flat they found a scalpel still embedded in his stomach with his body lying beneath a banner saying “When Satan Lives”.

They also found imitation human skulls and a coffin in which Manuela slept during the day….

Neither of the two self-styled devil worshippers showed the slightest emotion as the sentences were read out to a courtroom dotted with supporters and admirers of the bizarre couple, many dressed in black and holding roses.

….When she was on the stand, Manuela’s lawyer asked her if she had actually signed over her soul to the devil. “That was two-and-a-half years ago, on the night before Halloween,” she replied, adding in quasi-Biblical language: “That was when I placed myself in, and swore myself, to, the service of our Lord, his will to perform.”

Her Lord, though, was Satan, and he had come to play a big role too in the life of Daniel, the car parts salesman she met through an advert he placed in a heavy metal magazine in August 2000. “Pitch-black vampire seeks princess of darkness who hates everything and everyone,” he wrote.

She and her husband were arrested after being spotted at a petrol station after a nationwide manhunt. Police found a list in their flat of their intended future victims. There were 16 names on it.

Manuela, in verbal testimony, and Daniel, in a statement read to the court, both denied murder on the grounds that they were acting on a command from a higher authority. “I got the order to sacrifice a human for Satan,” Daniel insisted.
http://www.guardian.co.uk/world/2002/feb/01/uk.johnhooper

Argentinean courts confirm boy was killed in satanic ritual
Buenos Aires, Argentina, Jan 28, 2008 (CNA)

In Argentina the trial of Cesar Beguiristain has begun, the 20 year-old leader of an Afro-Brazilian, satanic cult accused of carrying out the ritual killing of a 12 year-old street boy. Last week Beguiristain confessed to killing “Ramoncito,” a street boy who the cult leader said “had agreed to sell his soul to the devil.”

….According to prosecutor Gustavo Schmitt, Beguiristain “broke down and confessed to decapitating the boy, but he claimed that it was not his idea and that he was hired to do the killing during a satanic game.”

Schmitt said seven people have been detained in the case, but that authorities are still seeking other individuals “who organized and financed the murder.”
….According to the investigation, the boy was raped, decapitated and dismembered in an Afro-Brazilian ritual. The witness to the crime said the method of killing caused the boy immense pain and was a source of excitement for his killers….
http://www.catholicnewsagency.com/news/argentinean_courts_confirm_boy_was_killed_in_satanic_ritual/

National Center for Prosecution of Child Abuse
National District Attorneys Association
NDAA TORTURE COMPILATION (May, 2010)
IDAHO IDAHO CODE ANN §18 1506A. RITUALIZED ABUSE OF A CHILD

DEFINITION
(1) A person is guilty of a felony when he commits any of the following acts with, upon, or in the presence of a child as part of a ceremony, rite or any similar observance:
(a) Actually or in simulation, tortures, mutilates or sacrifices any warm blooded animal or human being;
(b) Forces ingestion, injection or other application of any narcotic, drug, hallucinogen or
anaesthetic for the purpose of dulling sensitivity, cognition, recollection of, or resistance to any criminal activity;
(c) Forces ingestion, or external application, of human or animal urine, feces, flesh, blood, bones, body secretions, nonprescribed drugs or chemical compounds; (d) Involves the child in a mock, unauthorized or unlawful marriage ceremony with another person or representation of any force or deity, followed by sexual contact with the child;
(e) Places a living child into a coffin or open grave containing a human corpse or remains;
(f) Threatens death or serious harm to a child, his parents, family, pets or friends which instills a well founded fear in the child that the threat will be carried out; or
(g) Unlawfully dissects, mutilates, or incinerates a human corpse.

ILLINOIS 720 IL CS 5/12 33. RITUALIZED ABUSE OF A CHILD Sec. 12
33. Ritualized abuse of a child. (a) A person is guilty of ritualized abuse of a child when
he or she commits any of the following acts with, upon, or in the presence of a child as part of a ceremony, rite or any similar observance: (1) actually or in simulation, tortures, mutilates, or sacrifices any warm blooded animal or human being;
(2) forces ingestion, injection or other application of any narcotic, drug, hallucinogen or
anaesthetic for the purpose of dulling sensitivity, cognition, recollection of, or resistance to any criminal activity;
(3) forces ingestion, or external application, of human or animal urine, feces, flesh, blood, bones,
body secretions, nonprescribed drugs or chemical compounds;
(4) involves the child in a mock, unauthorized or unlawful marriage ceremony with another person or representation of any force or deity, followed by sexual contact with the child;
(5) places a living child into a coffin or open grave containing a human corpse or remains;
(6) threatens death or serious harm to a child, his or her parents, family, pets, or friends that instills a well founded fear in the child that the threat will be carried out; or
(7) unlawfully dissects, mutilates, or incinerates a human corpse.

LA REV STAT ANN §14:107.1. RITUALISTIC ACTS
A. (1) The legislature hereby finds that this enactment is necessary for the immediate preservation of the public peace, health, morals, safety, and welfare and for the support of state government and its existing public institutions.
(2) The legislature further recognizes that:
(a) The preamble to the Constitution of Louisiana affirmatively states “We, the people of
Louisiana, grateful to Almighty God for the civil, political, economic, and religious liberties we enjoy, and desiring to protect individual rights to life, liberty, and property; afford opportunity for the fullest development of the individual; assure equality of rights; promote the health, safety, education, and welfare of the people; maintain a representative and orderly government; ensure
domestic tranquility; provide for the common defense; and secure the blessings of freedom and justice to ourselves and our posterity, do ordain and establis
h this constitution.”
(b) The state, under its police power, may enact laws in order to promote public peace, health, morals, and safety.
B. (1) For purposes of this Subsection, “ritualistic acts” means those acts undertaken as part of a ceremony, rite, initiation, observance, performance, or practice that result in or are intended to result in:
(a) The mutilation, dismemberment, torture, abuse, or sacrifice of animals.
(b) The ingestion of human or animal blood or human or animal waste.
(2) The acts defined in this Subsection are hereby determined to be destructive of the peace, health, morals, and safety of the citizens of this state and are hereby prohibited.
(3) Any person committing, attempting to commit, or conspiring with another to commit a ritualistic act may be sentenced to imprisonment for not more than five years or fined not more than five thousand dollars, or both.
C. (1) No person shall commit ritualistic mutilation, dismemberment, or torture of a human as part of a ceremony, rite, initiation, observance, performance, or practice.
(2) No person shall commit ritualistic sexual abuse of children or of physically or mentally disabled adults as part of a ceremony, rite, initiation, observance, performance, or practice.
(3) No person shall commit ritualistic psychological abuse of children or of physically or
mentally disabled adults as part of a ceremony, rite, initiation, observance, performance, or practice.
(4) Any person who commits, attempts to commit, or conspires with another to comm
it a violation of this Subsection shall be sentenced to imprisonment for not less than five nor more
than twenty five years and may be fined not more than twenty five thousand dollars.
D. Each violation that occurs under the provisions of this Section shall be considered a separate violation.
E. The provisions of this Section shall not be construed to apply to generally accepted agricultural or horticultural practices and specifically the branding or identification of livestock.
F. The provisions of this Section shall not be construed to apply to any state or federally
approved, licensed, or funded research project.

MONTANA MONT CODE ANN §45 5 627 RITUAL ABUSE OF MINOR
(1) A person commits the offense of ritual abuse of a minor if the person purposely or knowingly and as part of any ceremony, rite, or ritual or of any training or practice for any ceremony, rite, or ritual:
(a) has sexual intercourse without consent with a per
son less than 16 years of age; commits assault, aggravated assault, assault on a minor, or assault with a weapon against a victim less than 16 years of age; or kills a person less than 16 years of age;
(b) actually or by simulation tortures, mutilates, or sacrifices an animal or person in the presence of the minor;
(c) dissects, mutilates, or incinerates a human corpse or remains in the presence of the minor;
(d) forces upon the minor or upon another person in the presence of a minor the ingestion or the external bodily application of human or animal urine, feces, flesh, blood, bone, or bodily secretions or drugs or chemical compounds;
(e) places a living minor or another living person in the presence of a minor in a coffin or open grave that is empty or that contains a human corpse or remains; or
(f) threatens the minor or, in the presence of the minor, threatens any person or animal with death or serious bodily harm and the minor reasonably believes that the threat will or may be carried out.
http://www.ndaa.org/pdf/Toture_Statutory_Compilation%5B1%5D.pdf

New York May Ease Statute of Limitations for Decades-Old Child Sex Abuse Claims, Sixth Circuit Rejects Commonsense Approach to Child Pornography Restitution

March 9, 2013 Comments Off on New York May Ease Statute of Limitations for Decades-Old Child Sex Abuse Claims, Sixth Circuit Rejects Commonsense Approach to Child Pornography Restitution

New York May Ease Statute of Limitations for Decades-Old Child Sex Abuse Claims

Bill Would Ease Path to Court for Yeshiva U. Victims
By Paul Berger Published March 07, 2013, issue of March 15, 2013.

Adults abused as children decades ago in New York could file civil lawsuits against their abusers and the institutions that employed them, if a national surge of legislative reform reaches Albany.

Advocates for child sex abuse victims say that this year, the prospects look good for a bill that sank four times previously following strong opposition from Catholic and ultra-Orthodox groups. If passed, the legislation could ease the way for a slew of lawsuits against Jewish and Catholic institutions accused of failing to report accounts of child sex abuse to law enforcement authorities.

“I’ve never been more optimistic we can succeed in 2013,” the bill’s sponsor, Assemblywoman Margaret Markey, said.

Yeshiva University may also be casting a wary eye toward Albany as it continues to investigate a scandal involving abuse allegations first reported by the Forward and dating back four decades.

Read the Forward’s COMPLETE COVERAGE of the allegations of abuse against staffers at Yeshiva U. high school.

The bill, known as the Child Victims Act, still faces a real test in the state senate where a key Democrat, Jeffrey Klein, indicated he would not support it….
http://forward.com/articles/172412/new-york-may-ease-statute-of-limitations-for-decad/

Sixth Circuit Rejects Commonsense Approach to Child Pornography Restitution
By James R. Marsh on March 8, 2013

Last week, the Sixth Circuit issued this confusing decision on child pornography restitution.

The Court held that the child pornography restitution statute contains both a cause-in-fact requirement—i.e., a showing that the defendant’s conduct actually caused the victim’s losses—and a requirement that the cause be proximate.

The Court found that “the statute still allows victims to collect more restitution than under earlier and concurrent restitution statutes. The statute expands the definition of victims and the categories of losses for which victims can receive restitution and makes restitution mandatory. In addition, the list of recoverable losses that the statute provides confirms the breadth of what is a foreseeable consequence of defendants’ actions.”

The Court concluded that “a proximate cause showing is necessary for restitution awards under § 2259, meaning the losses must be both “directly attributable” to the defendant’s offense, and “reasonably foreseeable.”….
http://www.childlaw.us/2013/03/sixth-circuit-rejects-commonse.html

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